October 28, 2010
Dear SEC Review Committee
I already sent one email to comment on the proposed changes regarding 12b-1 fees. I would like to add to my input on the proposal that a B/D may be able to lower- or define its own sales charge.
I work in small town, middle America. We have hundreds of clients that we help who have anywhere from $5,000 to 100,000. I believe with the proposed changes these people will be 'left out in the cold'.
The focus on many advisors is to get bigger and bigger accounts with fewer and fewer clients. This leads to a lack of service already to the smaller 'accumulation-mode' client. If b/d's can arbitrarily drive down their sales charge it will lead to what I believe is a huge lack of service to the middle market.
I can work on a volume scale in small town NY- but driving down the fees even more I will be forced to change my practice or charge a fee which hardly anyone wants to pay when then don't have to. I had a meeting last night where a client didn't want to pay another advisor $500 for a retirement analysis, when I do them as a value-added service.
I agree with the 12-b1 changes to disclosure but would strongly, with all due respect recommend keeping the current choices of A or C share for clients who want it.